Further Evidence Against Lawful Development of Blackrod Waste Incineration Plant

September 15th, 2016

Application 97204/16
CERTIFICATE OF LAWFUL DEVELOPMENT FOR THE PROPOSED INTRODUCTION OF ADDITIONAL FUEL INPUTS TO EXISTING GASIFICATION PLANT.

As the consultation period has now closed I have directed this directly to you as I think it is a serious issue that you should be aware of.
In a letter from the agent [letter from agent 21-Oct 2008] it was stated that facility would consume 61 tonnes of wood per day. That statement is contradicted by the technical information provided by the equipment manufacturers, BEL in document 49910_3. On page 6 of this document it states that each module consumed 250 kg of wood an hour and creates 250 Kwh of electricity. As the proposed facility has 16 modules (4Mwh) meaning the facility will consume 4 tonnes an hour or 96 tonnes a day.
Even though the agent provided incorrect information the correct tonnage is less than the 100 tonnes a day threshold (when an EIA is mandated). Therefore the original application was not compromised by the incorrect information. Unfortunately this is not the case for this latest application.
Defra state that the calorific value of wood is 14.7 Gj/tonne or 14.7 Mj/kg (table 11 of 2012 Guidelines to Defra / DECC’s GHG Conversion Factors for Company Reporting https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/69554/pb13773-ghg-conversion-factors-2012.pdf )
The calorific value of RDF is shown to be 6.5 Mj/kg Note 1 (section 3.2.2. Table 2 of A CLASSIFICATION SCHEME TO DEFINE THE QUALITY OF WASTE DERIVED FUELS http://www.wrap.org.uk/sites/files/wrap/WDF_Classification_6P pdf.pdf )
As the calorific value of RDF is less than wood more RDF will need to be used to generate the facilities 4 Mw of electrical energy.
96 tonnes of wood contain 1411.2 Giga joules of energy to generate this with RDF you would need 217 tonnes a day.
If a change of condition is granted in this case it would allow a facility to operate without carrying out an EIA that is mandatory for facilities burning more than 100 tonnes a day.
The applicant has not stated how much NOx will be emitted when using RDF as fuel. The wildlife trust commented on another application for a Biomass plant in the area that they were very concerned about NOx emissions on Red Moss SSSI. They stated in their comments on application 82447 (82447_09-A4_Wildlife_Trust_comments-151733.pdf)
“In particular I am very concerned about the effect which emissions from the proposed development will have on the Sphagnum mosses which occur on Red Moss. Deposition as low as 1 g/m2/yr of nitrogen can have a significant negative effect on Sphagnum growth (Gunnarsson and Rydin 2000). In addition due to the nature of Red Moss (it is a lowland raised bog) any nitrogen addition to the site will bio-accumulate in the bog and result in long term effects on the biodiversity and carbon storage potential of the site.”
These issues make it vital that this change should be considered by a full planning application.
There has been a material change to the facility in that a greater quantity of fuel will now be used.
If permission is granted by change of condition it will lead to a facility being approved without an EIA that will consume more than the 100 tonnes a day limit that requires a mandatory EIA.
The applicant does not detail the change in emissions resulting from the change to RDF so their impact on Red Moss SSSI cannot be assessed.

I have assumed the worst case energy value (class 5) as the application does not specify what if any class of RDF is to be used.
As this mechanism is seeking to change the definition of wood fuel to include RDF there would be no option to add another condition. So as the applicant would be free to use any fuel that conformed to the term RDF therefore it is reasonable to consider the RDF with lowest calorific value.